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Failure to state a claim upon which relief can be granted
Definition Failure to state a claim upon which relief can be granted is a defense to a legal claim. It means that the claimant has failed to present sufficient facts which, if taken as true, would indicate that a violation of law had occurred or that the claimant was entitled to a legal remedy. Overview In U.S. federal courts, the defense is set forth at Federal Rules of Civil Procedure, Rule 12(b)(6). To defeat a motion to dismiss filed pursuant to Rule 12(b)(6), a plaintiff must plead "enough facts to state a claim to relief that is plausible on its face."Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) (full-text); Reliable Consultants, Inc. v. Earle, 517 F.3d 738, 742 (5th Cir. 2008) (full-text); Guidry v. American Pub. Life Ins. Co., 512 F.3d 177, 180 (5th Cir. 2007) (full-text). A claim meets the "plausibility test" While a complaint need not contain detailed factual allegations, it must set forth "more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do."Twombly, 550 U.S. at 555 (citation omitted). The “factual allegations of complaint must be enough to raise a right to relief above the speculative level . . . on the assumption that all the allegations in the complaint are true (even if doubtful in fact)."Id. (quotation marks, citations, and footnote omitted). When the allegations of the pleading do not allow the court to infer more than the mere possibility of wrongdoing, they fall short of showing that the pleader is entitled to relief.Iqbal, 556 U.S. at 679. In reviewing a Rule 12(b)(6) motion, the court must accept all well-pleaded facts in the complaint as true and view them in the light most favorable to the plaintiff.Sonnier v. State Farm Mutual Auto. Ins. Co., 509 F.3d 673, 675 (5th Cir. 2007) (full-text); Martin K. Eby Constr. Co. v. Dallas Area Rapid Transit, 369 F.3d 464, 467 (5th Cir. 2004) (full-text); Baker v. Putnal, 75 F.3d 190, 196 (5th Cir. 1996) (full-text). In ruling on such a motion, the court cannot look beyond the pleadings.Id.; Spivey v. Robertson, 197 F.3d 772, 774 (5th Cir. 1999) (full-text), cert. denied, 530 U.S. 1229 (2000). The pleadings include the complaint and any documents attached to it.Collins v. Morgan Stanley Dean Witter, 224 F.3d 496, 498–99 (5th Cir. 2000) (full-text). Likewise, "'documents that a defendant attaches to a motion to dismiss are considered part of the pleadings if they are referred to in the plaintiff's complaint and are central to plaintiff's claims.'"Id. (quoting Venture Assocs. Corp. v. Zenith Data Sys. Corp., 987 F.2d 429, 431 (7th Cir. 1993)). The ultimate question in a Rule 12(b)(6) motion is whether the complaint states a valid claim when it is viewed in the light most favorable to the plaintiff.Great Plains Trust Co. v. Morgan Stanley Dean Witter, 313 F.3d 305, 312 (5th Cir. 2002) (full-text). While well-pleaded facts of a complaint are to be accepted as true, legal conclusions are not "entitled to the assumption of truth."Iqbal, 556 U.S. at 679 (citation omitted). Further, a court is not to strain to find inferences favorable to the plaintiff and is not to accept conclusory allegations, unwarranted deductions, or legal conclusions.R2 Invs. LDC v. Phillips, 401 F.3d 638, 642 (5th Cir. 2005) (full-text) (citations omitted). The court does not evaluate the plaintiff's likelihood of success; instead, it only determines whether the plaintiff has pleaded a legally cognizable claim.United States ex rel. Riley v. St. Luke's Episcopal Hosp., 355 F.3d 370, 376 (5th Cir. 2004) (full-text). Stated another way, when a court deals with a Rule 12(b)(6) motion, its task is to test the sufficiency of the allegations contained in the pleadings to determine whether they are adequate enough to state a claim upon which relief can be granted.Mann v. Adams Realty Co., 556 F.2d 288, 293 (5th Cir. 1977) (full-text); Doe v. Hillsboro Indep. Sch. Dist., 81 F.3d 1395, 1401 (5th Cir. 1996) (full-text), rev'd on other grounds, 113 F.3d 1412 (5th Cir. 1997) (full-text) (en banc). Accordingly, denial of a 12(b)(6) motion has no bearing on whether a plaintiff ultimately establishes the necessary proof to prevail on a claim that withstands a 12(b)(6) challenge.Adams, 556 F.2d at 293. References Category:Litigation Category:Definition